Case Digest (G.R. No. 205307)
Facts:
People of the Philippines v. Eduardo Golidan y Coto-Ong, Francis Nacionales y Fernandez, and Teddy Ogsila y Tahil, G.R. No. 205307, January 11, 2018, First Division, Leonardo-De Castro, J., writing for the Court. The respondents below were charged in three Informations filed on September 5, 1995 with (1) rape with homicide (victim Elizabeth Leo), (2) murder (victim Namuel Aniban, a one‑year‑old), and (3) frustrated murder (victim Cherry Mae Bantiway, then ten years old). The three accused were Eduardo Golidan (Golidan), Francis Nacionales (Nacionales), and Teddy Ogsila (Ogsila); Golidan and Nacionales are the appellants before the Supreme Court.The Regional Trial Court (RTC), Branch 61, Baguio City, after plenary trial that included medical and lay testimony and repeated photo and physical lineups, convicted all three accused on August 18, 1999. The RTC found that the lone surviving child witness, Cherry Mae Bantiway, though afflicted with cerebral palsy, was competent and credible; medico‑legal evidence established fatal blunt‑force injuries to Elizabeth and Namuel and serious head trauma to Cherry Mae, while semen and a blood‑stained one‑liter Coca‑Cola bottle and ashtray were recovered from the scene. The RTC sentenced each accused to death for rape with homicide (later affected by legislation), reclusion perpetua for murder, and an indeterminate term for frustrated murder, and ordered damages.
The case was initially subject to automatic review but, pursuant to the Court’s 2004 resolution transferring certain death‑penalty cases for intermediate review, the case was transferred to the Court of Appeals. On April 25, 2012 the Court of Appeals affirmed the RTC’s convictions but modified penalties and damages. The appellants (and Ogsila earlier) raised assignments of error contesting Cherry Mae’s competency, the sufficiency of identification evidence, the existence of conspiracy, admissibility of lineup identifications, and the sufficiency of their alibi and denial defenses. The Office of the ...(Pro-only)
Issues:
- Was Cherry Mae Bantiway competent to testify despite her cerebral palsy?
- Were the identifications and other evidence sufficient to support convictions beyond reasonable doubt?
- Could conspiracy among the accused be inferred from the evidence?
- Does the absence of counsel at police lineups render the identifications inadmissible or fatally taint the in‑court identification?
- Did the appellants’ alibi and denials create reasonable doub...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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